Webinar Question with Dr Breysse as set by Toxics Action Center Wednesday, 4.17.19
Dear Dr Breysse,
Please pardon the length of this letter. It is the first and only time the discussion of PFAS in PPE has come before a ranking member of our government.
As founder of this issue I have not had a seat at the table in PFAS hearings and discussions. While congress and senate are sympathetic, we are relegated to ‘waiting and hoping a PFAS chairperson grants us a hearing’ so that we may express our findings to the public. We have been unsuccessful for over three years for various well intended reasons.
In September of 2017, Environmental Attorney Robert Bilott submitted this 196 page letter to CDC/ATSDR, EPA, and (then) Attorney Jeff Sessions, demanding testing and studies for first responders PFAS exposure due to AFFF and PPE.
https://www.documentcloud.org/documents/3988104-Firefighter-Letter.html
It was only 15 months ago January 2018, we learned that firefighters are wearing staggering amounts of PFOA in new, never-worn turnout gear. It was only discovered because a housewife questioned the chemical coatings used in our turnout gear.
This discovery was not initiated by any fire service group, by any government group, by any worker protection group.
We were fortunate enough to have Nuclear Physicist, Professor Graham Peaslee of Notre Dame University , perform the initial testing of a set of turnout gear I acquired by posting the need for a set on a media page. He performed the first test. The fluorine content was so high it was counted in ‘volume’. He then sent it off for commercial testing.
The test results may be found here in the February 2018 article written by Station Pride. https://station-pride.com/2018/02/18/fire-gear-laboratory-test-results/
As you can imagine, we do not have understanding of what we are exposed to. If the testing was pulling only a ‘fraction of the potential’ that is in the gear (new gear, not contaminated with products of combustion), we are at a loss to understand what we have been repeatedly exposed to. My husband answered 6 calls a day on Rescue 1 for over 23 years. When he wasn’t in his gear, his, and 80 other sets were hanging next to the rigs in the station bays. Outer shells of PPE are made of Kevlar/Nomex and a mix of PBI. Kevlar (as per their 1983 msds) degrades in UV lighting. Your neighborhood fire station will have it’s bays open most of the day. You can easily see the gear. That gear has been degrading in that spot for decades now.
When the PEAS PFAS Concept Plan came out in August of 2018 we were shocked to see firefighter ‘omitted’ due to occupational exposure. As we have grown cynical of both the EPA and the CDC it appears to me that reason was to tip the scale in favor of the outcome that would benefit the government. The firefighters were drinking the water, showering in the water, cooking in the water, it would surely impact the outcome of a ‘water’ study. By omitting the firefighters, you are, in-fact, tipping the scales against the entire PEASE community by omitting a population of occupationally exposed firefighters. Young children and babies also drink the water, bathe, eat cooked food, and, are on heavily fluoridated carpets regularly, and , rightfully so, they are part of the PFAS study. While I can’t presume what year Portsmouth Fire Department discontinued use of toxic Class B AFFF, Russ Osgood did say (below) that it has been years since he used it.. and his PFAS serum numbers are high.
Even with a 47 page letter from Environmental Attorney Robert Bilott on August 12, 2018, along with bipartisan letters from Senators Shaheen and Murkowski, and Members of Congress Jim McGovern, and Brian Fitzpatrick, this has still not persuaded you to fund a sub group study for firefighters.
https://www.youtube.com/watch?v=fUcHiV2kI5s
The discussion with Dr Schnoor of NIOSH during the February 7 2019 PEASE PFAS CAP left more questions than answers.
I was disappointed in the lack of knowledge of the PFAS/PPE issue. As well as the PFAS in Firefighter in general and dare I say, lack of preparation.
This is our lives sir., we are a community of 1.4 million. And we have no seat at the table. Unlike the PFAS water affected communities across the nation, we have no where to turn with our concerns, questions, testing (none available to the average firefighter)…..
We are marginalized at this time. I would caution anyone who would discuss with me the other ‘products of combustion’… We know. We’ve been in this for 30 years.. We get it. We need CDC/ATSDR to study us for the PFAS coatings in our PPE that surpass any garment on the market and may only be comparable to industrial textiles.
On Thursday Feb 7, 2019 during the PEASE PFAS CAP the team members discussed fire fighters and what role if any they will have in the CDC/ATSDR National PFAS Study.
https://www.youtube.com/watch?v=fUcHiV2kI5s&fbclid=IwAR2EEiI6ls0OzHlV7NyS3ZfVJvwPDQVkmW2veAnnq6g8OmBeZqrHyiD9xSw
The outcome was not in favor of the fire service, and, for the foreseeable future we will not be part of the National PFAS Study. Being immersed in this issue for 3? years now I have a good idea of what firefighter PFAS studies have taken place, and what studies are being done or planned. That said, we still have no overall plan for the fire service. We have numerous studies on firefighters and AFFF, or AFFF, or firefighters and cancer, products of combustion, ppe. But, we are missing a National Fire Service PFAS Protocol. We have no planning for a PFAS plan for the fire service. We know many of the 58,000 stations in the Nation held AFFF at one time, trained with it, and still store it. We know we have PFAS laden PPE degrading in firehouses across the nation, and we know we are wearing PFAS laden PPE as that is the only chemical that can meet NFPA 1971 per the manufacturers themselves.
The fire service has 1.4 million exposed Firefighters with no one to call on for answers. Unlike The water affected communities we have no agency overseeing us in the manner that is done for water affected communities.
We have no agencies coming to check our fire stations for drinking water where we cook, shower, and drink. We have no ability to ask for prescriptions for serum draws. Having worked on two firefighters in the last month seeking serum draws it is a very complicated series of steps. In our case, in Massachusetts, my husbands physician is still seeking justification for his wanting a serum draw. In a case across the country, a highly exposed firefighter had his city administration deny his request for a serum draw. He is now paying for the test out of pocket.
We have no agency we can call on for community meetings like the military affected bases have around the country.
By omitting the FFs from the study Breysse Is tipping the scale in favor watered down results in an affected community. Firefighters did in fact drink, shower, and cook on this base. PFAS laden PPE is washed in extractors and then sent out into the water systems.
Daily actions in firehouses directly impact the water of affected military bases. PPE washed in fire-stations goes into the water ways and water treatment systems.
THE September 2018 DISCUSSION OF FF’S IN SEPTEMBER MINUTES OF PEASE CAP COMMITTEE shows the Testing for Pease advocates Andrea Amico and Alayna Davis asking about firefighters. These minutes also show Firefighter Russ Osgood sharing his own concerns about his PFAS levels and questioning if not AFFF where is it coming from?
https://www.atsdr.cdc.gov/sites/pease/documents/Pease-CAP-meeting-sept-2018-508.pdf
Page 31 Andrea Amico is asking about the monies for the PEASE PFAS Study, and Dr Breysse is answering that they have no restrictions on how to spend it (that is my understanding as I read this at least …)
DR. BREYSSE: So Congress gave the Department of Defense the authority to do direct transfers of resources to CDC.
MS. AMICO: Uh-huh.
DR. BREYSSE: They did not have that authority before so that authority means they give us the money and there’s no strings attached. So just to give you an example, the way we got the money before we had to sign a memorandum of understanding, essentially, with the DOD that described our roles together and we are, practically speaking, a subcontractor to the DOD for that first 10 million dollars and we had to agree, you know, to all these provisions going forward. None of that will have to be done with the future monies because now Congress said to the DOD you can just give money directly to CDC, you don’t have to go through the subcontract mechanism. So our hands are not tied in that regard and so we’re free to consider things like having open competition for sites for the multi-site study.
Page 35 Andrea is asking about the firefighters:
MS. AMICO: So I’m very happy to hear that, so thank you very much. So I guess my last question is, I just want to be clear because it recently came to my attention that the firefighters that were exposed here at Pease would not be eligible for this study and I would just really like to better understand from ATSDR why that is and talk about if they’re not eligible for this study are there plans to put them in their own study
DR. BOVE: Okay. I can answer part of that. I think it’s important that firefighters be evaluated as a separate group because their exposures are unique. And I think that — so that’s one issue. And the entity that would most likely follow firefighters is the entity that’s already doing that which is NIOSH. They have three firefighter cohorts. Unfortunately, when I discussed this issue with them several years ago they said that these firefighters were not using AFFF very much so they didn’t think it was a good cohort to study. So a different cohort would have to be identified. But the reason we’re not including them in this study is because we’re focusing on drinking water, we want to use the drinking water contamination levels to predict what serum levels are over time and do a cumulative serum, PFAS serum evaluation similar to what the C8 study did. And the advantages to doing that are that if you use the actual biomonitoring results for PFAS there are some bias issues that could arise from particular end points and particular kidney end points, but there are other end points that are involved with reproductive end points that we’re not looking at, but we wanted to be able to not only use the biomonitoring results in these analyses but also to estimate cumulative PFAS serum levels. And it’s hard enough to do that with the drinking water. We would — it would be really impossible for us to figure out in addition to the drinking water exposures what amount of PFAS a firefighter might’ve been exposed to either through training or putting a fire out. And so it’s complicated. When the C8 study they included industrial workers but that’s because — and along
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with the community exposures but that’s because they already had done estimates of cumulative exposure, PFAS exposure with these workers with information from the work place itself so they can do that. And oftentimes they separate the two groups out in the analysis as well. You know, so again, because of this issue of the firefighters are diff — the industrial workers in this case were different than the community exposures. So in order to maintain a clean study which — it will be difficult to estimate cumulative exposure from the drinking water situation, we’re going to have to do some modeling, we’re going to have to make some assumptions, it’s not easy to do that. It just adds a whole other layer of complexity and uncertainty by adding in occupational exposures, whether it’s firefighters or other occupations that involve PFAS not from drinking water but from working with the material either in production or manufacturing or whatever. So those are the reasons why we excluded all occupational PFAS exposures from this study. One thing to keep in mind is that the evidence that we get from these studies, this study, the multi-site study and all the other studies that have been done, both the C8 studies, the occupational studies, all that evidence can be used to
ll that evidence can be used to understand what the health effects of these chemicals are. We did something similar at Lejeune. We were asked by the Veterans Affairs to evaluate the evidence and most of the evidence that we looked at and used in building a case for which diseases the VA should give presumption for were based on occupational studies, they weren’t based on Camp Lejeune studies because most of the information is from occupational studies. In this case with PFAS there are some occupational studies. Some of them are very small and in that case they’re weak because they’re small numbers. More of the studies are from community exposures so we’re learning a lot more about PFAS health effects from those. All that evidence though is relevant both to firefighters, to workers who work with it and to people who get exposed from drinking water as well as from consumer products. So that — so you don’t have to be, in other words, you don’t have to be in a study to have all this evidence relevant to your situation.
MS. AMICO: Okay. I just have a couple follow up questions to that. So has ATSDR — is it, I guess, let me start with, is it appropriate for ATSDR to approach NIOSH and say we have a group of firefighters at Pease who had drinking water exposure and occupational exposure and we’re going to be doing multi-site study? I imagine other communities have firefighters that are also exposed, you know, across the nation that will be participating in the multi-site study. So is there any way to make this a separate study and would NIOSH be willing to partner with the ATSDR or is it appropriate for you guys to talk to them about that?
DR. BREYSSE: Yes, yes.
MS. AMICO: Okay. And have you talked to them about —
DR. BOVE: Yes.
MS. AMICO: — it recently?
DR. BOVE: Not recently, no I have not. No.
MS. AMICO: Okay.
DR. BOVE: But again, we’d have to think about what the best cohort would be. The the best cohort would be. There are firefighters at airports. There are firefighters at the military bases. There are firefighters who work in our communities. And the ones that NIOSH has been following apparently, according to them, did not use AFFF much and so that wouldn’t be a good cohort. But so you’d have to think about what would be the best group to follow of firefighters, you know. And you know, so we have to think about that. I mean it seems to me that there are a lot of fire — — there are a lot of firefighters and fire training going on at the military bases. The question is how good the data is to identify them. The data I’ve seen from the Defense Manpower Data Center, which is the personnel data for the military, is iffy when it comes to occupational information. So it may be difficult to do — to really assemble a good cohort there. But these are the kinds of questions we’d have to ask. How — what’s the best information we can use to actually define a cohort that we’re pretty sure uses AFFF at least on a routine basis or more often than not as opposed to, as I said, the NIOSH cohort. And then how can we assemble them, what information will help us assemble that group and then we can follow them over time. So that’s — these are the questions NIOSH also has to grapple with.
MS. AMICO: Okay. I would just like to continue to revisit these conversations because I know that is a group of people we don’t want to forget about here. And I hear you that everyone will benefit from this study and we’re all going to benefit from that information. But I think when people are exposed and they had no control on that exposure and they want to participate in something, it’s like a way — it’s you know, I don’t know, just I would hate to think that these people who have had a significant exposure, not only through the drinking water, through the foam, now we know it’s in their gear too. I just, I don’t know, maybe I’m coming at it from a more emotional place but I feel like we need to be paying attention to that group too and we can’t forget about them and they’re actually a really important population we need to learn from because of their exposure. So I want to continue this conversation about how the firefighters here can somehow play into maybe not this study but another possible study, whether it’s with NIOSH or whatever. I think we need to keep those conversations open.
Russ Osgood is a firefighter:
His question put it in perspective about his serum level and now the PPE….
MR. OSGOOD: I have the same, I just — while we’re on the firefighter thing — I had the same — I had the exact same question. And I understand why because it’s a drinking water study that we’re removing firefighters, I understand that. But is there any way that we can, I know you can talk to NIOSH or I can approach NIOSH and request this, but just saying because of AFFF to me is not enough.
Like I think we need to say there’s multiple places that firefighters are exposed to this, through our firefighting equipment, AFFF, you know, there’s lots of areas. So I just, I’m a little concerned that we’ve narrowed it down just to AFFF because I’ve been in the fire service for quite a long time and we used AFFF early on in my career but we haven’t used AFFF in years so it’s, you know, but it’s still our — my levels are up and many of my members’ levels are up and that’s concerning. If it’s not the drinking water, you know, and it’s not AFFF, there’s something else in there.
DR. BOVE: Right. And again —
MR. OSGOOD: I’d love to get the answers to that
DR BOVE: Yeah.
MR. OSGOOD: And I know that’s outside of what you’re studying, but if we can work together to try to move that along that would be wonderful.
DR. BOVE: Well there may be, again, NIOSH is following these cohorts.
MR. OSGOOD: Yeah.
DR. BOVE: And they said they don’t use AFFF much, but they wear this equipment -
MR. OSGOOD: Which they’re probably accurate.
DR. BOVE: — but they wear the equipment as you were pointing out. There may be some value, you know, if we can convince NIOSH of this or if it fits in with their protocol to do that, work with them, with the cohorts they’re following. Again, I would think that if we can identify those firefighters who are actually training with it and using it more routinely and that would maybe be military bases and airports. If we can identify —
DR. BREYSSE: Of course some industrial firefighters as well.
DR. BOVE: Yeah, if we can find —
DR. BREYSSE: Refineries and chemical plants.
DR. BOVE: Yeah, right. Yeah, and again you’d have to be able to figure out a way to identify them.
MR. OSGOOD: Okay. D
DR. BREYSSE: So Cliff, I think Alayna’s had her —
CDR MUTTER: There’s somebody on the phone.
DR. CARIGNAN: Pardon me, can I jump in on that comment? Can you guys hear me?
(SIDE NOTE: this is Courtney Carignan, she’s been magnificent every step of the way in this issue with PPE when I found her 2/3 years ago… she is one of the dozen scientists that has been helping in this PPE journey, when it began 3 years ago I began reaching out to area scientists and she was magnificent with her immediate responses and information. dc)
DR. BREYSSE: Sure.
CAPT SOMERS: Sort of.
DR. CARGINAN: So I’ve been talking with firefighters as well, this is — I think we all hear from them quite frequently, are concerned about it, and I recently heard from a firefighter who works at a base that uses AFFF. But NIOSH came out years ago, I mean three years ago and collected a bunch of data and came back telling them to to wear PPE, but haven’t done much else and I know that I’ve reached out to NIOSH. I’ve suggested to firefighters with concerns to reach out to NIOSH and really it doesn’t seem like any of us are getting anywhere. At least getting much of a response from NIOSH and I was just wondering if you all would be able to help — help community firefighters to sort of get an audience with NIOSH and get them to engage in a similar way that you guys are engaging with the Pease community. Maybe that is a way to move forward on this issue.
DR. BREYSSE: Well, we’ll do our best. That’s a great suggestion.
DR CARIGNAN: Thank you.
DR. BREYSSE: So Alayna your card was up first but if you don’t mind, if you have a firefighter question —
MR. LAZENBY: I do.
DR. BREYSSE: — okay, good. Just want to keep a thread going.
MS. DAVIS: Okay. So I have a few questions. One was I thought I read something in the proof of concept that was regarding sampling tap water, so can you clarify who that would apply to? Was it part of the unexposed population to make sure that those people weren’t exposed at their homes?
DR. BOVE: No, that was never in the protocol.
MS. DAVIS: It wasn’t?
MR. BOVE: No.
MS. DAVIS: Okay. So I’ll have to look back at that. All right. So can you tell us again what years the participants would’ve had to have been exposed on Pease for the Pease study?
DR. BOVE: Right. Well in the protocol we’re saying from any time between 2004 and 2014. 2004 was we thought that after 15 years, if your last exposure was later — was longer ago than 15 years ago, given the half-life of PFHxS, we thought we wouldn’t see much in the blood so we thought that would be a cut off. And looking at those who went through the biomonitoring program, the vast majority were exposed in that window. So — but we can relax that. It just makes it harder to figure out — if they weren’t exposed — if their last exposure was 2003 or earlier it may be hard to estimate what their levels are, given what we see now, you know. So that’s one of the concerns. But we’re not going to — again, we’re going to focus on those who went through the biomonitoring. If we can we’d like to limit it to those people who were last exposed no more than 15 years ago. If we have to relax that we will to reach our sample size goals, but hopefully we won’t have to do that.
MS. DAVIS: Okay. So if anyone within that time frame participated in fire training exercises on Pease they would be eliminated from the study because that would be considered an occupational hazard?
DR. BOVE: Yeah. If they have occupational exposure, whether it’s a firefighter or industrial worker who worked with the substance, yeah.
MS. DAVIS: Okay.
DR. BOVE: So it’s just, again, we want to focus on drinking water exposures so that we can actually estimate cumulative PFAS serum levels over time.
(….. The exposed community is being omitted because they want to determine drinking water exposure over a level of time. We’re being excluded for this reason? We did drink the water, shower in the water, cook with the water, wash PPE with the water…… dc )
MS. DAVIS: Okay. And then — I don’t know if I’m going to ask this question so that you get it, but hopefully you do. So in the end the goal, is it to — is it to determine just the risks from drinking water exposure to PFAS or just — or is it actually based on the serum level in your blood, no matter how you were exposed?
MR BOVE: It’s based on the serum level.
MS. DAVIS: Okay.
DR. BOVE: It’s based on the serum level of both the actual measured serum level and as I said, the cumulative serum level. Again, following the model of the C8 study.
MS. DAVIS: Okay. So then the people who were exposed occupationally still would get data from that because it’s based on what their blood level would be versus how they were exposed.
DR. BOVE: Well, no. The — again, we’re going to exclude those people who were occu —
DR. BREYSSE: The data will be —
MS. DAVIS: The data —
DR. BREYSSE: — informative — M
S. DAVIS: — yeah, the data will give them information —
DR. BREYSSE: — of that.
DR. BOVE: Right. That’s what I was saying before —
MS. DAVIS: Okay
DR. BOVE: — yeah. I’m sorry, I misunderstood your question.
MS. DAVIS: Okay. Yeah, okay. Thank you
DR. BREYSSE: So just to be a little bit clearer, ATSDR’s mission is to address community health concerns about hazardous waste and hazardous materials released into the environment. So our entrée here is the contaminated water from an industrial site, in this case, from a defense facility. That’s what Congress asked us to do, that’s our mandate and so that’s why we’re focusing on the water. We want to understand a little bit about maybe what the consumer products people are exposed to. Remember there’s a big burden of exposure from consumer products as well, but we’re really focusing on the water because that’s ATSDR’s mission. Cliff.
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Well, there is MUCH hazardous waste from our PPE….. What comes off the PPE and into the water systems of communities is of great concern. Professor Peaslee is studying that right now. Professor Peaslee is finishing up his testing on 20 years worth of new, never worn PPE. He will send his work for peer review and publish promptly.
This is the cohort study that Dr Breysee mentions as having been used to study 30,000 firefighters. We call it the FOX Study. Here are the serum results : https://www.researchgate.net/publication/270662382_Biomonitoring_in_California_Firefighters_Metals_and_Perfluorinated_Chemicals
Conclusions: Perfluorodecanoic acid concentra-tions were three times higher in this firefighter group than in NHANES adult males. Firefighters may have unidentified sources of occupational exposure to perfluorinated chemical
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On September 5, 2017 Environmental Attorney Robert Bilott along with C8 Science Panel member Dr Paul Brooks, and Fire Chief Jeffrey Hermes, sent the following 195 page letter to CDC/ATSDR, EPA, and (then) US Attorney Jeff Sessions demanding studies and testing for first responders.
https://www.documentcloud.org/documents/3988104-Firefighter-Letter.html
On September 12, 2018, when he saw the first responders were omitted from the CDC/ATSDR PEASE PFAS Concept Plan, he sent a 48 page letter challenging that decision.
On October 4th, 2018 Attorney Bilott filed a National Class Action with Fire Chief Kevin Hardwick. They are seeking testing and studies for anyone harmed by these chemicals.
https://theintercept.com/2018/10/06/dupont-pfas-chemicals-lawsuit/
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Dr Breysse ,
The letter below from Commander Kenny Fent of NIOSH is from July of 2018… It is in response to the many emails I send/sent regarding the non action of government to act on checking fire stations for PFAS exposure. Due to years of training with AFFF and of course the still unknown amounts of PFAS in our turnout gear.
This letter is from Commander Kenny Fent of NIOSH:
July 25, 2018
Diane Cotter
Dear Diane Cotter:
Thank you for your email regarding perfluoroalkyl substance (PFAS) contamination in the fire service for career, volunteer, wildland, and military first responders. The National Institute for Occupational Safety and Health (NIOSH) is familiar with this concern and actively engaged in research on occupational exposure to these compounds and other persistent organic compounds. NIOSH is also part of a large network of federal agencies, including the Environmental Protection Agency (EPA) and Department of Defense (DOD) among others, evaluating the exposure and risk of a number of PFAS compounds including GenX chemicals (also a member of the PFAS family). NIOSH regularly communicates our applicable research findings to these other federal agencies with the goal of expanding our collective understanding of human exposure to PFAS and other persistent organic compounds.
As you may know, PFAS were used in multiple products in the United States, such as stain resistant and water repellant coatings on fabrics and textiles, including those used in the fire service. PFAS were also used as surfactants in the aqueous film forming foams (AFFF) that fire departments may use to suppress industrial fires, chemical fires, or other fires that are difficult to suppress with water. Because of the environmental persistence, bioaccumulation, and toxicity concerns, many PFAS compounds have been phased out in the United States. In many cases, shorter-chain fluorinated compounds are being used as replacements in the aforementioned products. These replacements are much less persistent in the environment and are typically short-lived in the human body. However, further toxicity research on these replacement chemicals is needed. Because AFFF foams have long shelf lives, some departments may still have legacy PFAS-containing AFFF foams in stock.
NIOSH is currently engaged in ongoing research studies to examine PFAS exposure in the fire service. In a 2015 collaborative study with the University of Illinois, where firefighters suppressed controlled residential fires, NIOSH collected blood from 36 U.S. firefighters for the analysis of PFAS compounds. The results from this study may provide an indication of the biological levels of PFAS among a select group of firefighters. Data from this study are still undergoing analysis, but we hope to publish the findings within the next year.
NIOSH is also working with the Universities of Miami and Arizona on a prospective firefighter cancer cohort study. As part of this study, samples of firefighter participants’ blood are being collected for PFAS analysis. One goal is to expand this cohort to include firefighters who are more likely to use or have used PFAS-containing AFFF foams, such as industrial firefighter trainers. This study is still in the early phases, so it will take some time to publish the results.
Page 2 — Diane Carter
NIOSH is also considering other studies focused on occupational exposure to PFAS, including GenX chemicals.
Your email raised concern regarding the carcinogenicity of PFAS compounds. There are many risk factors for cancer, including diet, physical fitness, and chemical exposures. Firefighters may be exposed to numerous combustion byproducts that are known human carcinogens, including polycyclic aromatic hydrocarbons (PAHs), benzene, formaldehyde, and vinyl chloride. Much of the research at NIOSH has focused on these known human carcinogens. It is currently unknown how PFAS-containing AFFF foams and firefighting textiles contributed to the systemic levels of PFAS in firefighters, and further, how these exposures then contributed to health outcomes. While studies certainly indicate that firefighters have an increased risk of certain types of cancer, linking these cancers to specific exposures is very difficult.
Generally, scientists can only provide evidence for causality, but can rarely provide proof of causality. It becomes even more difficult to provide evidence of causality when the exposure has changed substantially over time. Because some PFAS compounds have been phased out of a variety of products, including recent turnout gear ensembles, firefighters’ exposures may also be different today than decades ago. This is further compounded by the fact that firefighters could have PFAS exposures from combustion sources (depending on what is burning) or be exposed outside the workplace (depending on furniture, carpeting, etc. used in the home). Despite these complexities, we are fully dedicated to understanding firefighters’ exposures to all chemicals and identifying ways of minimizing those exposures and any related health effects.
Thank you for your concern and outreach on this important topic. Please be on the lookout for informative articles on firefighters’ exposures to PFAS and other persistent organic compounds as we publish findings from our research over the next few years. These results will also be shared broadly with the U.S. fire service organizations.
Sincerely,
Kenneth Fent, PhD, CIH
Research Industrial Hygienist
CDR, U.S. Public Health Service
National Institute for Occupational Safety and Health
Dear Kenny,
With all due respect, this response does nothing to support a national protocol for the fire service.
Every single fire station in the nation that trained with AFFF is at risk.
Every single fire station in the nation that houses PPE is at risk.
Every single fire fighter should have serum tested.
Every single fire fighter should be included in the National PFAS Register.
I’m at a loss to understand why the alarm is not being sounded for the fire service here in the USA as it is in Australia, where their union has ordered the serum testing for all fire fighters?
Or why we are not conducting symposiums as is done in Europe to educate the fire service on the chemicals used in the making of the protective ensembles. And the end of life disposal methods.
We must have limits of PFAS chemicals in our gear now. Not in the future. As has been done in the EU by the demands of ECHA.
25ppb PFOA in PPE and 1ppm precursors.
We must have labeling in our gear now on a national scale as has been instituted in Washington State. Notifying the fire fighter that the garment contains PFAS chemicals which are known to be endocrine disruptions.
The 385 page ECHA background document on PFAS goes into great discussion about fire fighters.Their occupational exposure from the gear via routes of exposure; dermal, ingestion, inhalation. From the gear.
These are all protocols we must provide now. Not in the future.
You are the most respected man in the fire service Kenny. You and I have spoken on the phone about this issue. We spoke about the events in Europe and I sent you all of the material on their events.
This is not enough. We must have a plan now. Today.
We know the chemicals are in the gear. The new PFAS may be even worse.
We know they live in fire stations that have had gear degrading for decades. We know in the 80’s, 90’s, the fire service drilled using AFFF. If they drilled with AFFF in their own yards, they ARE at risk for water / soil contamination.
We need a national plan for the fire service. The testing and studies are wonderful and needed. But this is not a plan Kenny. We know they are occupational exposed. The new CDC PFAS Toxicological Profile states it.
We need a national fire service PFAS protocol.
Where do we turn now? If CDC is not going to do this? Who will put this national project together?
Sincerely,
Diane Cotter
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This 1977 NIOSH document shows just how long we can play kick the can down the road… we are still not any closer to a comprehensive plan for the fire service.
https://www.cdc.gov/niosh/pdfs/77-193a.pdf?id=10.26616/NIOSHPUB77193
Dr Breysse, this petition is signed by 9,000 firefighters, across the USA. We are now demanding testing and studies of America’s Bravest, in the same manner that is afforded the water affected communities.
This petition outlines the deception, omissions, negligence by government and public corporations. Please note the hundreds of comments of firefighters who wish to express their exposures and concerns.
I also ask you to please read through the events of this issue as outlined on the petition. What it took to get here, and please acknowledge that we still have NO seat at the table.
While we appreciate the hearings from members of IAFF in the senate this past year, their focus is on PFAS exposure via AFFF. Our focus is on PPE.
While Dr Bove discusses a cohort that may / may not be focused around AFFF, we want you to understand that our turnout gear is contributing to your problem. That our gear will end up in your landfills.
Please see this calculation of amounts of PFOA and other PFAS , from degrading PPE as written by Professor Graham Peaslee, nuclear physicist of Notre Dame:
https://medium.com/@dianecotter/my-january-16-2019-stakeholder-statement-at-massdep-pfas-mrl-petition-by-toxics-action-center-and-8c49bf7facf2
In addition, this is the only known list I am aware of that keeps track of the ‘non-military’ fire stations that have elevated PFOA/PFAS. It is kept by me. A housewife in New Hampshire. Surely we can do better for America’s Bravest. No one is sending these firefighters letters to test their water. It’s simply not required. May this ‘Facebook Note’ now serve to act as official notice to CDC .
In the coming days, Professor Graham Peaslee will release the results of the independent turnout gear study we asked him to undertake. We had no government sponsorship. It was funded by Last Call Foundation Honoring Firefighter Michael Kennedy, and Notre Dame University. (Along with the sale of baked goods and craft items from fire wives).
Professor Peaselee has been working pro-bono for us for many, many, months.
While I do know the results, I am not at liberty to disclose..
I am able to share my opinion that you have a disaster on your hands.
My question, will you slice a portion of the funds you have at your discretion to urgently organize a multi million dollar study for the firefighters of this nation?